Environmental and
occupational health and safety laws and regulations are complex and often
confusing.

There are literally thousands of
environmental safety and health laws and regulations developed and
administered by a confusing array of national, state and local governmental
agencies - both in the United States and abroad. In addition, there are
hundreds of international standards and directives that may be considered
"other requirements."

Determining which of these legal and other
requirements are applicable to your operations is often a difficult task. It
is, however, a critical task. Failing to comply with a requirement may lead
to substantial fines or other penalties. Complying with regulations that are
not required may use resources that could be better spent elsewhere.

When implementing an environmental or safety
and health management system, compliance must be addressed as an integral
part of your management system. Pursuant to ISO 14001, organizations are
required to do the following:

What are Other Requirements?

When
discussing environmental compliance, ISO 14001 uses the
terminology of "legal requirements and other requirements to
which the organization subscribes." What does this mean?

When environmental management system standards
were first being developed, there was a common misconception
that environmental compliance requirements were limited to
regulations issued by environmental agencies such as US EPA.
Those developing the ISO 14001 standard wanted to make sure it
was clear that the compliance obligation is broader than this. It
includes complying with all the environmental
commitments an organization has made. This includes commitments
made as a member of an industry trade group, to customers in
contractual documents, to shareholders and other business
partners, to regulators in consent documents and to the public
in policy statements.

Establish a policy which includes a
commitment to compliance with applicable legal and other requirements

Establish, implement and maintain a
procedure to identify applicable legal and other requirements

Ensure that applicable legal and other
requirements are taken into account in the management system

Periodically evaluate the organization's
compliance with the applicable legal and other requirements

Report on the results of the compliance
evaluation to Top Management

Four Steps to
Developing an Effective EHS Compliance Program

There are four steps to establishing an effective EHS Compliance Program:

Developing and implementing a
procedure for identifying your compliance requirements

Developing processes to ensure those
compliance obligations are met

Developing and implementing a process
for evaluating your compliance status

Reporting to Top Management about your
compliance status

Step 1 -- Identify your Legal and Other
Requirements

Before you can address your legal and
other requirements you need to know what they are.

How ENLAR Can Help

Preparation of a
Site-Specific Compliance Guidebook

One requirement of ISO 14001 is that
the company must develop a procedure to "identify and have access to legal
and other requirements to which the organization subscribes, that are
applicable to the environmental aspects of its activities, products or
services."

ENLAR Site-Specific Compliance
Guidebooks help meet this requirement. First, it identifies your legal
requirements. Second, it sets out how each regulation can quickly and
easily be accessed using paper, electronic and web-based resources.
Finally, it will assist you in continuing to identify your compliance
obligations on an on-going basis.

An ENLAR Guidebook will
provide a concise and easy-to-understand summary of the environmental,
safety and health regulations that actually apply to your organization

Contents of an
ENLAR Site-Specific Compliance Guidebook

List of Compliance Requirements by
Subject Area

Detailed Compliance Summaries for each
Regulation

Individually-Tailored Compliance Audit
Checklist

Information on Accessing Regulatory
Requirements

Contact Information for Regulatory
Agencies

Step 2 - Develop your Compliance Program

Once you know what your legal requirements
are, you can develop a compliance program to ensure that each requirement
is addressed when and how it must be done. This may include:

Completing and filing reports with
environmental agencies

Applying for licenses or permits

Implementing product or workplace
labeling

Developing written plans or procedures

Undertaking periodic inspection or
sampling programs

How ENLAR Can Help

ENLAR can assist with preparation of
required reports or permit applications, help you development written
procedures and provide you with e-mail reminders of up-coming compliance
requirements.

Step 3 Evaluate your Compliance Status

ISO 14001 requires that you develop a
procedure to periodically evaluate your compliance status. This procedure
needs to address who is going to do this, when and how often it is going
to be done and the process to be used. In addition, this procedure needs
to address other legal issues such as US EPA
Audit Policy.

How ENLAR can Help

ENLAR has assisted a number of organizations with compliance
evaluations. This includes researching difficult compliance questions,
assisting in developing evaluation tools such as audit checklists and
conducting compliance assessments and internal investigations.

Step 4: Report to Top Management

Top Management cannot make a commitment to
compliance without being informed about what this means. ISO 14001
requires that one of the inputs to management review is information on the
results of the compliance evaluations performed.